Hearing Statement – Matter 7 Leeds Site Allocations Plan On behalf of Network Space August 2017 Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017 1. Introduction 1.1. This is a Hearing Statement prepared by Spawforths on behalf of Network Space in respect of: • Matter 7: Selection of sites allocated for development 1.2. Network Space has significant land interests in the area and has made representations to earlier stages of the emerging Site Allocations Plan and is specifically interested in securing an employment allocation for their land at Warren Farm, Micklefield (Site 1269). 1.3. The Inspector’s Issues and Questions are included in bold for ease of reference. The following responses should be read in conjunction with Network Space’s comments upon the previous version of the Leeds Site Allocations Plan, dated September 2015 and March 2017. 1.4. Network Space has also expressed a desire to attend and participate in Matter 7 of the Examination in Public. 2 Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017 2. Matter 6 – Selection of sites allocated for development 2.1. In addition to the general matters raised by Network Space in respect of Matter 2, the following individual sites are not considered “sound”: • over 17ha of land in Garforth (Sites EG1-35 and EG1-36) which has significant ground condition issues, is constrained by the now safeguarded route of HS2 and the landowner is seeking residential uses on the site; • 36.23ha of land at Leeds Bradford Airport (Site EG3) which is part of the long term plans for the airport; • 5 hectares of employment land at the proposed new settlement at Parlington (MX2- 39) which is the subject of major objection; and • 17.51ha at Thorp Arch Trading Estate which is the subject of a residential planning application. 2.2. These are now considered in more detail. Sites EG1-35 and EG1-36 (Hawks Park North) 2.3. Network Space objected to the identification of these employment sites within the Site Allocation Plan. These sites form part of an existing UDPR employment allocation (E4:13) that has not come forward. Network Space is encouraged that these sites have been reduced to take into account some aspects of HS2 but do not consider that these changes are sufficient given the technical constraints to delivery, HS2 implications and the landowners own aspirations for the site. 2.4. In accordance with the Framework existing UDPR allocations “should be regularly reviewed” and should not be identified for employment use “where there is no reasonable prospect of a site being used for that purpose” (para 22). Whilst the area of land affected by HS2 has been removed from these allocations, the potential for additional land to be sterilized and the impact on viability or deliverability of the land to the north of HS2 which is landlocked between the HS2 railway and the M1 Motorway has not been taken into account. The affect being that following implementation of HS2 there is only feasibly circa 11ha of land that 3 Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017 could possibly accommodate employment development, which is a circa 12.8ha reduction from the original proposed allocation. 2.5. However, in addition to HS2 the site suffers from significant ground condition issues and the landowners own aspirations that the site should be developed for residential use. In response to the Publication Draft consultation the landowner states that the “employment scheme is not viable or deliverable”; that “the Council need to plan for the fact that Hawks Park may not come forward for its intended use”; that “the proposed construction of the HS2 Phase 2 line through the centre of the site further detracts from its deliverability for large floorplate employment development”; and that the Council should “consider the allocation of this site for a residential-led mixed-use scheme”. Given that the landowner states that the sites are unviable and will not come forward for employment purposes, the sites do not accord with the Framework and are not available, suitable or achievable. The sites (EG1-35 and EG1-36) should therefore not be allocated for employment and the Site Allocations Plan should be modified accordingly. EG3: Land at Carlton Moor / Leeds Bradford Airport 2.6. Network Space considers that the allocation of 36.2ha of general employment land at Leeds Bradford Airport will not meet the short to medium term employment need in the area. The land is allocated for the future long term expansion of Leeds Bradford Airport and the creation of an employment hub. However, the scheme is dependent on the preparation of a Supplementary Planning Document and the delivery of strategic infrastructure which will guide how development will progress. The success of the allocation is dependent upon future transport infrastructure including new and improved links to the airport. The allocation is therefore for the long term and will not satisfy employment needs of the district in the short to medium term, especially those along the A1 / M1 corridor. MX2-39: Parlington Estate 2.7. Network Space strongly objects to the draft allocation MX2-39 (Parlington estate) which identifies 5 ha of general employment land at the proposed new settlement at Parlington. 2.8. The Core Strategy sets a framework for identifying allocations. Policy SP1 states that development will be focused towards the Main Urban Area, Major Settlements and Smaller Settlements. Policy SP1 also states that the identification of land should be towards previously developed sites within the settlement, followed by other suitable infill sites and 4 Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017 sustainable extensions to settlements. Furthermore, the policy states that a selective Green Belt review will occur to “direct development consistent with the overall strategy”. 2.9. The Core Strategy through Policies SP8 and SP9 identifies the priorities and level of employment growth required, including providing employment land in accordance with the settlement hierarchy. Policy SP8 also specifically supports employment development in existing locations / sites for general industry and warehousing to take advantage of existing services, accessibility and infrastructure (including rail infrastructure). Furthermore, Policy SP10 indicates the priority order for the review of the Green Belt, which is first the Main Urban Area, followed by the Major Settlements and Smaller Settlements. Only exceptionally will sites be considered outside of the settlement hierarchy, where they will be in sustainable locations and are able to provide a full range of services and facilities and are more appropriate in meeting the spatial objectives of the Plan than the alternatives within the settlement hierarchy. Within this context, “sustainability” is of paramount importance given Spatial Objective 7 to “deliver economic development which makes the best use of land and premises across the district in sustainable locations, accessible to the community and wider labour market”. 2.10. In relation to locating development, the national policy through the Framework is specific in stating that planning should “actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling and focus significant development in locations which are or can be made sustainable” (para 17). 2.11. In order to be “sound” the Site Allocations Plan must follow the principles of the Framework and the Spatial Approach established through the Core Strategy. For the Parlington Estate Mixed Use allocation to be found “sound” in employment terms it must be more appropriate than the alternatives within the settlement hierarchy to accord with Policy SP10. It is clear that the Warren Farm, Micklefield site is an extension to an existing modern employment site (Peckfield Business Park) within walking distance to a train station (in accord with SP8) which forms an extension to a “Smaller settlement” (in accord with SP1 and SP10). The Parlington Estate Mixed Use proposal is a free standing new settlement that does not extend an existing employment site (contrary to SP8); does not lie adjacent to an existing public transport node (contrary to SP8) and does not form an extension to an existing settlement within the Settlement Hierarchy (contrary to SP10). In accordance with the Framework and Core Strategy, sites that are located within or adjacent to the settlement hierarchy (i.e 5 Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017 Micklefield) should be allocated before a greenfield new settlement that is poorly related to the settlement hierarchy and with poor accessibility credentials. As such, the Parlington Estate site should have been sieved out and should be removed from the Site Allocations Plan. 2.12. The creation of a new settlement in this location is not in accordance with the Core Strategy and would significantly harm the openness and purposes of the Green Belt in this location. It is apparent that there are significant environmental, heritage and technical constraints to the delivery of the Partington site and that detailed assessments should be undertaken and made available to demonstrate that the site is deliverable in accordance with the Framework. Furthermore, the site assessment notes that the site “fails all accessibility criteria” and scores 1 out of 5 for accessibility. Exceptional circumstances have therefore not been demonstrated and the site should be sieved out. The site therefore fails to accord with the principles of the Framework and should be deleted. Thorpe Arch 2.13. Approx. 17.5ha of current employment land at the Thorp Arch Trading Estate in the Outer North East area is the subject of a residential planning application and now an appeal against non-determination. Whilst the Council has previously been supportive of the principle of housing on the site, the City Plans Panel Report (20th July 2017) confirms that the Council do not support the planning application and will be contesting the appeal.